For the tax team, the practical execution of transfer pricing can present more frustration and confusion than legislation or regulation. While transfer pricing compliance is principally a matter for the tax team, responsibility for the execution of inter-company transactions requires shared responsibility with many other internal functions. This is made even more difficult in practice as there is rarely someone with oversight of the entire E2E process.
“Considering a more strategic approach that moves beyond typical ad-hoc activities and manual data collection, like a more efficient and aligned transfer pricing function, can help organizations realize a lot of value,” Williams said.
Ivan Williams, PwC Alberta Transfer Pricing Leader, has more than 10 years of transfer pricing experience, including audit defence and risk assessments. He is the author of a number of recent articles on transfer pricing, including contributions to the Canadian firm’s newsletter Transcend. He has co-authored articles for the Canadian Tax Journal and is a regular speaker for organizations such as the Tax Executive Institute and the Canadian Tax Foundation.
David Nickson is the PwC US Principal and Global Leader of the End to End (E2E) Transfer Pricing Practice for PwC. He develops E2E transfer pricing execution initiatives, helping clients develop their pricing strategies and embed them into their operational, accounting and IT functions.
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